All credit unions with more than $54 million in assets will be required to collect data associated with mortgage loan applications processed in 2023, the federal credit union regulator said Thursday.
In a “regulatory alert” (23-RA-02), the National Credit Union Administration (NCUA) said the data collection requirements for federally insured credit unions under the Home Mortgage Disclosur Act (HMDA, Regulation C) included three additional criteria to the asset threshold for 2023. Under those, the data must be collected if the credit union:
- Had a home or branch office in a Metropolitan Statistical Area (MSA) on Dec. 31, 2022;
- Originated at least one home purchase loan (other than temporary financing such as a construction loan) or refinanced a home purchase loan, secured by a first lien on a one-to-four-unit dwelling during 2022; and
- Originated at least 25 covered closed-end mortgage loans in each of the two preceding calendar years (2021 and 2022) or at least 200 covered open-end lines of credit in each of the two preceding calendar years (2021 and 2022).
“If your credit union meets all four criteria, you must collect HMDA data during calendar year 2023 and submit the data to the CFPB no later than March 1, 2024,” the alert warned.
Regulatory Alert (23-RA-02): Home Mortgage Disclosure Act Data Collection Requirements for Calendar Year 2023